First Coast Photography: 7800 Point Meadows Dr., Suite 717 Jacksonville, Fl 32256 T: ( 904) 392

- 6543 F: ( 904) 379

- 0158

J eremy D. Smith

T: + 1 904 392 6543 jhill@cooley.com

October 1st

, 201 5

U. S

. D epartm ent o f Transportation

Docket M anagement S ystem

1200 New Je rsey A ve., SE Washington, D C 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) & (b); 91.7 (a);91.9 (b) (2);91.103(b); 91.109;91.119; 91.121; 91.151(a);91.203(a) & (b);91.405 (a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & (b).

Dear S ir or M adam:

Pursuant t o S ection 333 of the FAA M odernization and Reform A ct o f 201 2 (the Reform Act) a nd 14 C .F.R. P art 11, First Coast Photography Inc

. , o perator of Small U nmanned Airc raft

S ystems (“sUASs”) e quipped to c onduc t aerial phot ography for t he real estate industry for photography and f ilming of houses

, hereby appl ies for a n exempti on from t he l isted Federal

A viation Regulations ( “FARs”) t o al low c ommercial oper ation of i ts s UASs, so long a s suc h operations a r e conducted within and under t he conditions out lined herein or as may be established by t he FA A a s r equired by S ection 333.

As descr ibed m or e fully bel ow, t he r equest ed exemption would permit the operation of
small, un manned and r elatively i nexpensive sUAS under co ntrolled conditions in airs pace t hat i s 1) limited 2) pr edetermined 3) c ontrolled as to access and 4) w ould provide safety

enhancements t o the already s afe ope rations i n the real estate industry pr esently us ing

c onventional ai rcraft. Approval of t his ex empti on would thereby enhanc e s afety and fulfill t he Secretary o f Transportation’s ( the FA A A dministrator’s) r es ponsibilities t o “...establish requirements for

t he safe oper ation of s uch ai rcraft s ystems i n t he nat ional airspace system.”

Sec tion 333(c) o f the R eform A ct.

The nam e and address o f the applicant i s:

First Coast Photography Inc.

Attn: Jeremy Smith

Ph: 904-392-6543

Email: jeremysphd @ gmail .com Address: 7800 Point Meadows Dr.

, Suite # 717

, J acksonville

, FL 3 2256October 1st

,

201 5 Pag e Two

Regulations f rom which the exemption is requested:

14 CFR Part 21

14 C.F. R. 45.23(b) 14 CFR 61.113 (a) & (b) 14 C.F.R. 91.7 (a) 14 CFR 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F. R. 91.119

14 C.F.R. 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b)

This ex emption application is expressly su bmitted to fulfill C ongress’ goal i n passing Section 333(a) t hrough ( c) o f the Reform A ct. This l aw di rects the Secretary o f Transportation

to consider

w hether c ertain unmanned aircraft s ystems may oper ate safely i n the national airspace sy stem ( NAS) b efore c ompletion of t he r ulemaking required unde r S ection 33 2 of the

Reform A ct. I n making this det ermination, t he Secretary i s r equired t o de termine which types o f

UASs do not cr eate a hazard to users o f t he N AS or t he publ ic or pose a t hreat t o nat ional security in lig ht o f the following:

• The UAS’s s ize, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the operator.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the nat ional airspace system.” Id. §333(c) (emphasis added) 2

.

The Federal Aviat ion Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, that includes sUASs, from the requirement that all civil aircraft must

have a current airworthiness certificate.

2 Applicant interprets this provision to place the duty on the Administrator to not only process applications for exemptions under section 333, but for the Administrator to craft conditions for the safe operation of the UAS , if it should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval.

F irst Coast Photography: 7800 Point Meadows Dr., Suite 717 Jacksonville, Fl 32256 T: ( 904 ) 392

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Pag e Three

The A dministrator

m ay gr ant an exemption from a r equirement o f a r egulation prescribed

under su bsecti on (a) or ( b) o f this se ction or a ny s ections 44702

- 44716 of this t itle if t he

Administrator finds t he exemption in the publ ic i nterest. 49 U.S.C. §44701 (f) See also 49 US C §44711(a); 49 U SC §447 04; 14 C FR §91. 203 ( a) ( 1).

First Coast Photography Inc ’s s UASs will utilize rotorcraft, w eighting 55 or f ewer l bs.

i nc luding pay load. They oper ate, under nor mal c onditions at a speed of no more t han 50 knots

and hav e the capability t o hover, and move in the v ertic al and horizontal pl ane simultaneously. They w ill operate onl y i n line of s ight

. Such operations w ill i nsur e that t he s UAS w ill “ not c reate

a hazard to users o f the nat ional a irspace system o r t he public.”

Given the small s ize of the sUASs i nvolved and the restricted sterile environment w ithin which they w ill oper ate, t he applicant falls squarely within that z one of s afety ( an equivalent

level o f s afety) i n w hich Congress env isioned that the FAA must, by ex emption, al low

commercial oper ations o f U ASs to commence i mmediately. Also due t o the size of the UASs

and the r estricted areas i n which the relevant s UASs w ill oper ate, appr oval o f t he appl ication
presents no national s ecurity i ssue. Given the clear di rection in Section 333 of t he R eform A ct, the authority c ontained in the Feder al A viation Act, as amended; t he strong equivalent l evel of safety s urrounding the proposed operations, and the significant publ ic ben efit, i ncluding enhanced safety, reduction in environmental i mpacts, i ncluding reduced e missions as sociated with allowing U ASs for real estate photography o perations

, the grant o f t he requested exemptions is i n the publ ic i nterest. Accordingly, t he applicant respec tfully r e quests that t he

FAA gr ant t he requested ex emption without del ay.

AIRCRAFT AND E QUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the already safe real estate photography operations conducted with sUAS's that have already received exemption by the FAA under Section 333

.

These limitations and conditions t o which First Coast Photography Inc. ag rees t o b e
bound when conducting c ommercial o perations unde r an FA A i ssued exemption include:

acceptable for

s UAS f ilming operations for t he real estate industry. Applicant submits t his

m anual a s a C onfidential doc ument u nder 14 C FR 11. 35 ( b) a s t he ent ire manual c ontains

pr oprietary i nformati on that t he a pplicant has no t and w ill not s hare with others. The

manual contains op erating conditions and procedures that ar e not av ailable to the public

and ar e pr otect ed from r elease under t he Freedom o f Information Act 5 USC 552 et.seq

.

Reform A ct S ection 333 (b).

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201 5 Pag e Four

1. The s UAS w ill w eigh less t han 55 lbs.

2. Flights w ill be operated within line of s ight o f a pi lot and /or obs erver. 3. Maximum t otal flight t ime f or ea ch oper ational flight w ill be 30 minutes. Flights w ill be

terminated at 25% ba ttery po wer r eserve should t hat oc cur p rior t o the 30 minute

limit.

4. Flights w ill be operated at an altitude o f no m ore than 4 00 feet A GL

. 5. sUAS pi lot w ill be an FAA l icensed airman w ith at l east a sports pilot’s c ertificate

. 6. sUAS P ilot w ill be Pilot i n Comm and (PIC).

7. Pilot will hav e been trai ned i n operati on of UAS generally and received up -to-da te information on the particular U AS t o be operated

. 8. Written and/or

or al pe rmissi on from t he r elevant p roperty hol ders w ill be obtained.

9. All r equired permissions and permits w ill be obtai ned from t erritorial, s tate, c ounty or city j urisdictions, i ncluding l ocal l aw enf orcement, fire, or ot her appr opriate governmental a gencies.

10. If t he sUAS loses c ommunications o r l oses i ts G PS s ignal, the UAS w ill ha ve capability t o return to a pr e -de termined location within the Security P erimeter and

land.

11. T he sUAS will hav e t he capability t o abort a flight i n cas e of unpredict ed obstacles or emergencies.

14 C.F.R. P art 2 1, S ubpart H : Airworthiness C ertificates 14 C .F.R. §9 1. 203 (a) ( 1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements

for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the

size and operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular

UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated

without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.

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The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area. Unlike other civil aircraft, operations under this exemption

will be tightly controlled and monitored by both the operator, pursuant to the Manual’s requirements, and under the requirements and in compliance with local public safety requirements, to provide security for the area of operation as is now done with other

sUAS's that are already except under Section 333. L astly, application of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed of operati on, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. § 45. 23 ( b). Marking of t he Aircraft

The regulation requires:

When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

- sport," "experimental," or "provisional," as applicable.

Even though the UAS will have no airworthiness certificate, an exemption may be

ne eded as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word

“Experimental” c an be pl aced or an "N" number filled with the FAA

. Given the s ize of t he sUAV,

two -in c h lettering will be impossible. The w ord “Experimental” w ill be placed on t he fuselage i n compliance with §45.29 ( f).

The e quivalent l evel of s afety w ill be provided by hav ing t he sUAV m arked on its fuselage

as r equired by §45. 29 (f) w her e the pilot and others w orking with or observers within sight of t he

sUAV will s ee the identificati on of the UAS as “ Experimental " or with an appropriate "N" number.

The FA A has i ssued the following exemptions t o t his r egulation to E xemptions N os. 10700, 8738

, 10167 and 10167A.

14 C.F.R. § 61. 113 ( a) & ( b): P rivate Pilot P rivileges and Limitations: P ilot i n C ommand.

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Pag e Six

Sections 61.113 (a) & (b) limit private pilots to non -c ommercial operations

. Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to have a t least a sports pilot’s license rather than a commercial pilot’s license to operate this small UAS.

Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely

controlled with no living thing on board. The area of operation is controlled and restricted,

and a ll flights are planned and coordinated appropriately in advance for safe flights . The level of safety provided by the requirements exceeds that provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. The risks associated with

the operation of the sUAS are so diminished from the level of risk associated with

commercial operations contemplated by Part 61 when drafted, that allowing operations of

the sUAS as requested with a private pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. §91 .7(a): C ivil ai rcraft a irworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft,

should this exemption be granted, no FAA regulatory standard will exist for determining

airworthiness. Given the size of the aircraft and the requirements contained in the Manual for

maintenance and use of safety check lists prior to each flight, as set forth in Sections J, L and Q, an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) ( 2): C ivil Aircraft Flight M anual i n t he Aircraft.

No person may operate a U.S.

- registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. Section 91.9 (b) (2) provides:

The sU AS, giv en its si z e and configuration has no abi lity or pl ace to carry s uch a flight

manual on the ai rcraft, n ot onl y beca use there i s no pilot on board, bu t be cause there is no room

o r ca pacity t o ca rry su ch an i tem on t he ai rcraft.

The e quivalent l evel of s afety w ill be maintained by k eeping t he flight manual at the ground control poi nt w her e the pilot flying the sUAS w ill hav e immediate access to it. The FAA

has issued the followin g ex emptions t o t his r egulation: E xemption N os. 86 07, 8737

, 8738

, 9299

, 9299A, 9565

, 9565B

, 10 167, 10167A

, 10602

, 32 827, and 10700.

14 C.F.R. § 91. 103: P reflight ac tion

F irst Coast Photography: 7800 Point Meadows Dr., Suite 717 Jacksonville, Fl 32256 T: ( 904 ) 392

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This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. An equivalent level of s afety will be provided as set forth

in Sections J and K of the Manual. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.

14 C.F.R. §91 .109: Fl ight i nstruction :

Section 91.103 pr ovides that no pers on may oper ate a c ivil ai rcraft ( except a manned free

bal loon) t hat i s bei ng us ed for flight i nstruction unless that ai rcraft has fully functioning dual

controls.

s UASs and remotely pi loted aircraft, by t heir des ign do not hav e fully functional dual

controls. Flight c ontrol i s ac complished throug h the use of a c ontrol box that c ommunicates w ith

the aircraft v ia radi o communications. The FA A h as appr oved exemptions for f light t raining

without fully f unctional d ual c ontrols for a num ber

o f ai rcraft and for

f light i nstruction in experimental ai rcraft. S ee Exemption Nos.5778K & 9862A

. The equivalent level of s afety provided by t he fact that neither a pi lot no r

pas sengers w ill be carried i n the aircraft and by the size and speed of t he ai rcraft.

14 C.F.R. §91 .119: Minimum saf e al titudes

Section 91.119 es tablishes s afe al titudes for oper ation of c ivil ai rcraft. Section 91.119 (d)

allows hel icopters t o be operated at l ess t han t he minimums pr escribed, p rovided the person operating the helicopter c omplies w ith any r oute or al titudes p rescribed for hel icopters by t he

FAA. As t his ex empti on is for a sUAS t hat i s a helicopter and t he ex emption requests a uthority
to operate at al titudes up t o 400 AGL, an exempti on may be needed to al low s uch operations.

As set forth herein, ex cept for t he limited conditions stated i n the Manual, t he UAS w ill never

oper ate at higher

t han 400 AGL. It will ho wever be operated i n a restricted ar ea w ith security

per ime ter, where buildings and people will not be expos ed to operations w ithout their pr e

obtained consent.

The e quivalent l evel of s afety w ill be achieved given the si ze, w eight, sp eed of t he U AS

as w ell as t he location w here it i s ope rated. N o flight w ill be taken without the permission of the
property ow ner

or l ocal o fficials. Compar ed t o flight ope rations with aircraft o r rotorcraft

w eighti ng far

m or e t han t he maximum 5 5lbs. pr oposed herein and the l ack o f flammable fuel,

any r isk associated with these operations i s far l ess t han t hose presently prese nted w it h

conventional ai rcraft oper ating at o r bel ow 500 AGL

. In addition, t he l ow -al tit ude operations o f

the s UAS will ens ure separation between these small -UA S oper ations an d t he operations o f

conventional ai rcraft t hat must c omp ly with Section 91.119.

14 C.F.R. §91

. 121 Altimeter S ettings

First Coast Photography: 7800 Point Meadows Dr., Suite 717 Jacksonville, Fl 32256 T: ( 904) 392

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This regulati on requires each person oper ating a n aircraft t o maintain cruising al titude by

referenc e to an al timeter that i s s et “...t o the elevation of t he depar ture ai rport o r a n appropriate

altimeter s etting av ailable before departure.” As the sUAS m ay no t have a bar ometric al timeter,

but i nstead a G PS altitude read out

, an ex emption m ay be needed. An e quivalent l evel of safety w ill be achieved by t he operator, pu rsuant t o the Manual and Sa fety Ch eck lis t, confirming the al titude o f t he l aunch site s hown on the G PS al titude indicator be for e flight.

14 C.F.R. § 91. 151(a): Fuel R equirement s for Flight i n VFR Conditions

Section 91.151 ( a) p rohibits an individual f rom be ginning “a flight i n an ai rplane under

VFR c onditions unl ess (considering wind and forecast w eather c onditions) there i s enou gh fuel

t o fly t o t he first poi nt o f i ntended landing, and, as suming normal c ruising speed – (1) D uring t he day, t o fly a fter

t hat for a t l east 30 minute s; or ( 2) A t night, t o fly after t hat f or at least 45

minutes.”

The bat tery pow ering the s UAS pr ovides approximately 40 minutes o f po wered flight. To

meet t he 30 minute r eserve requirement i n 14 C FR §91. 151, s UAS flights would be limit ed to approximate ly 10 minutes i n length. Given the l imitations on the UAS’s p ropos ed flight area and

the location o f i ts pr oposed operations w ithin a predetermined area, a longer t im e frame for flight i n daylight or

ni ght VFR c onditions i s reasonable.

Applicant bel ieves that a n exempti on from 14 C FR §91. 151(a) f alls w ithin the scope o f prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporati on to operate

without c ompliance with FAR 91. 151 (a)). Operating the small U AS, i n a tightly c ontrolled area

wher e only peopl e and property ow ners or official r epresentatives w ho have signed w aivers w ill be allowed, w ith less t han 30 minutes o f r eserv e fuel, does no t en gender t he type of risks that Section 91.151(a) w as i nt ended to alleviate giv en the size and speed of the s mall UAS. Additionally, l imiting sUAS flights to 10 minutes w ould greatly r educe t he u tility f or w hich the exemption will be granted.

Applicant bel ieves t hat a n equivalent l evel of s afety c an be ac hieved by l imiti ng flights to

30 minutes o r

25 % o f ba ttery pow er

w hichever

happens first. This r estriction would be more

First Coast Photography: 7800 Point Meadows Dr., Suite 717 Jacksonville, Fl 32256 T: ( 904 ) 392

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- 0158The regulation provides in pertinent part:

(a) Except as provided in § 91. 715, no person may operate a civil aircraft

unless it has within it the following:

(1) An appropriate and current airworthiness certificate. . . .

(b) No person may operate a c ivil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization i ssued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to

passengers or crew.

The UAS fully loaded we ighs no more than 55 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the sUAS.

An equivalent level of sa fety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them, to the extent

the y are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789,
9789A, 9797, 9797A, 9816A, and 10700.

14 C.F.R. §91.405 (a); 407 ( a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

These regulations req uire that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airw orthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook as referenced in the Manual.(See Sections L and Q) An equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. As provided in the Manual, the operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most October 1st

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than adequat e t o retur n the sUAS t o i ts pl anned landing z one from any where in its l imited operating a rea.

Similar ex emptions hav e been granted t o ot her operations, i ncluding Exemptions
2689F, 5745, 10673

, and 10808.

14 C.F.R. §91

. 203 (a) an d (b): Carrying Civil Aircraft C ertification and Registration

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Pag e Ten

fam iliar w ith t he ai rcraft a nd best su ited t o m aintain the ai rcraft i n an ai rworthy co ndition to provide the equivalent l evel of safety.

*********

Pursuant t o 14 C.F.R. P art 11, t he following su mmary i s provi ded for publ ication in the

Federal Register, sh o uld it be det ermined t hat pu blication is needed:

Applicant seeks an exem ption from the following rules: 14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or less) in motion picture and television operations.

The oper ation of s mall U ASs, w eighting l ess t han 55 lbs., conducted in the s trict

conditions out lined above, w ill pr ovide an equivalent l evel o f s afety s u pporti ng the g rant of t he exemptions r equested h erein, i ncluding exempting the appl icant from t he requirements o f P art 21 and allowing c ommercial oper ations. These lightweight ai rcraft op erate at s low s peeds,

close to t he ground, and in a sterile environment and, as a result, a r e far s afer t han c onventional operations conducted w ith turbine helicopters ope rating i n close proximity t o the ground and people.

Sincerely,

J eremy D

. Smith First Coast Photography Inc.

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